HomeMy WebLinkAbout04/16/2002, 1 - RESPONSE TO REVISED REGIONAL HOUSING NEED FOR SAN LUIS OBISPO COUNTY San Luis Ob2spo Council of U' oVMV itnts
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Census Data Affiliate Pismo Beach
Service Authorityfor Freewa s and Expressways Sao Laps Coust°
Ronald L.DeCarli-Executive Director YSao Luis Obispo County
Date: April 8, 2002
Julie Bornstein, Director
California Department of Housing and Community Development
1800 Third Street, Suite 430
P. O. Box 952053
Sacramento, CA 94252-2053
Subject: Response to Revised Regional Housing Need for San Luis Obispo County
Dear Ms. Bornstein,
The purpose of this letter is to request a reduction in the regional housing need identified by
your agency for the San Luis Obispo region from the 18,892 indicated in your revised
allocation to 13,892 housing units based upon the following criteria:
1. A 1000 unit reduction due to an over-allocation by your agency of anticipated units
lost from the housing stock.
2. A 2000 unit reduction due to an inequitable over-allocation to San Luis Obispo
County as a result of flaws in the demographic model employed by your agency.
3. A 2000 unit reduction based upon the components of population change anticipated
by the California Department of Finance and by HCD to be experienced in the
SLOCOG region.
This revised SLOCOG proposed number is an effort by the Council of Governments to
achieve a potentially attainable regional housing needs allocation that is more fair and
recognizing the trends that have occurred over the last decade. The proposal of 13,892
attempts to remedy housing shortages within the local housing market and acknowledges
that surrounding areas are putting undue pressure upon our own market by their lack of
accommodation of their respective regional housing needs. We believe this revised number
is a more realistic target and does not attempt to recover the deficit in housing stock that has
accrued over decades during a single 7-year cycle.
1. Replacement unit data. HCD uses data on loss of housing stock collected statewide in
order to calculate a ratio of average units taken out of the local housing stock. The number
used in HCD's formula is 0.002. It is multiplied by the average number of housing units
foreseen for the planning period (the 2008 units — the 2001 units / 2). The number
determined for the SLOCOG region is 1587 units lost (as a result of demolition, deterioration,
disaster, or conversions to non-residential uses). While SLOCOG understands that the
method is useful on the aggregate level,these"estimates"that HCD makes for our local level
are inaccurate and misrepresentative of actual housing loss activity.
In an effort to arrive at a sound determination of lost housing stock, SLOCOG staff surveyed
our eight member jurisdictions asking them to review their records for a determination of an
average number of units lost over the recent 5-10 year period. The survey requested data
on replacement units of all types; demolition, conversions to non-residential space, and any
other types of single family and multiple family housing unit losses. The request was for data
that is verifiable and as up-to-date as possible. The results of the survey are displayed in the
Table A.
RECEIVED
1150 Osos Street, Ste. 202, San Luis Obispo,CA 93401 ♦ Tel. (805)781-4219 Fax. 8 5)
E-mail. slocog@slonet.org♦ Internet. http://www.slonet.org/-itM CITY COUNCIL
Table A
HOUSING UNITS REMOVED
Ave.Annual
JURIswcnoN 2[100 HOUSING UNITS
POPULATION UNITS Lost 94.01
ARROYO GRANDE 16,426 6.824_ :-4.75
ATASCADERO -Z'rt ......•-•••-•91735 -_6.66
EL PASO DE ROBLES ---______22'922 _______.____ 8t949 _____ -3.36__---
.. SOD
GRO\/ER BEACH 12'
MORF20_BAY 9,981 6,113 3.60
............
PISMO BEACH -8 629 . -51119 -4.33............LUIS_OBISPO 43:027 181871 .1000
_ otal INCORPORATED 139,540 61,036 -98.70
UNINCORPORATED 105,651 40.464 -17.27
TOT COUNTY 245,1911 101,502 -53.97
Total Units Lost-19942001 4tW.775
As Table A indicates, the rates of ho sing loss experienced in San Luis Obispo County do not approach the
level of the statewide average anticipated by HCD. The average number of units lost in the last 7.5 year cycle
is about 400, yet HCD is aggressi ly projecting housing losses of 1587 units - more than 3.7 times the
observed amounts based upon sujiveys of our communities. The difference between a projected 587 lost
units and SLOCOG's observed <400 lost units will provide for an ample "margin of error". SLOCOG requests
a reduction of 1000 units from the category of"calculated units needed to replace normal loss of units".
2. Inequitable Distribution of Anticipated Need. SLOCOG realizes that this is not the forum for reallocating
RHNA to all of the surrounding coastal counties, nor are we requesting such of HCD. Yet the fact remains
that our region, with the smallest economy and least amount of infrastructure, is being asked to accommodate
the greatest proportion of regional housing needs of any cantmLcoast county. Even if the HCD demographic
model is strictly applied and our housing n—ee is projected to be hightKthan that of neighboring counties, the
inherent flaw in the HCD projections lies in its ignorance of other factors hich directly relate to our region's
ability to facilitate explosive housing growth and the accompanying 9Trvices such growth predicates.
Counties can serve as manageable regional planning areas, but ignorinq the cross-county relationships,
particularly as they relate to housing choices and residential locations,l is poor planning at best and
detrimental to local communities at worst. t
The relatively higher housing prices in surrounding counties have undoubtedly contributed significantly to the
domestic out-migration witnessed along the coast between Santa Cruz and Ventura. Up until a few years
ago, San Luis Obispo was a refuge for homebuyers able to find relatively affordable housing that included a
"Central Coast" lifestyle. Such an influx to our area has caused housing prices to rise dramatically and
actually begin to approach prices in our neighboring counties. Because of this set of circumstances, HCD's
projection model, as it is currently used, demands that we continue this ,fend of absorbing what have been
equity rich migrants into our area. Throughout the 1990's the sunoundingicounties were (and are still) unable
or unwilling to provide for an adequate stock of housing options. San Luis Obispo County is clearly being
asked to not only accommodate our own housing needs, but those of surrounding coastal counties, as is
evident by our large proportion of immigration relative to surround areas. The current HCD process and
methodology supports and perpetuates this unhealthy dynamic.
SLOCOG is proposing that this be remedied, studied further, and corrected prior to the next HCD housing
needs allocation process. Until then, the only immediate solution is for HCD to lower the projection for San
Luis Obispo County by at least 2000 housing units on the basis of the inequalities evident in the proposed
allocation of units to these counties.
3. Components of Change. While strongly interrelated with the issue of distribution of anticipated need, the
details of the components of change can be both indicative of household formation rates and misrepresenting
of future trends. One of the driving forces of San Luis Obispo's observed growth rates marked by high levels
of immigration and moderate levels of natural increase over the last decade, was the fact that housing sites
were relatively affordable,jobs were available and this was, and is, an extremely desirable destination for job
seekers and retirees.
With the notable discrepancy between our housing prices and those of surrounding areas disappearing, the
high rate of immigration witnessed in the 1990's is likely to subside. HCD is basing SLOCOG's regional
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_ Table A ENT 2
HOUSING UNITS REMOVED
Ave.Annual
JURISDICTION 2000 HOUSING UNITS
POPULATION UNITS Lost 94-01
ARROYO GRANDE.................. ----- ..........
ATASCADERO 25.L768 9'7--3''-5- -6.66
.._...M •-------••-------------- ...--•-
EL PASO DE ROBLES �1' ----.....8,949 .......
BEACH ............. ........••-•--12,767....... 5,427 4=�.....
IvlORRO__BAY 9,981 .. ........ 6'� 13 •....-3'60-----
PISR10 BEACH---------- -------- ---- 8`� 5.119 -433
- -
SM LUIS OBISPO 43,027 ______18,871'[-------
_____10.00 __
--- 36.70
Total_INCORP0RATED ___--_____139,5110 _______61 ,038 _____ _ •_________
UNINCORPORATED 105.651 40,464 17.27
TOTAL COUNTY -245,191, 101 ,502 -53.97
Total Units Lost-19942007 1 -404.775
As Table A indicates, the rates of housing loss experienced in San Luis Obispo County do not approach the
level of the statewide average anticipated by HCD. The average number of units lost in the last 7.5 year cycle
is about 400, yet HCD is aggressively projecting housing losses of 1587 units - more than 3.7 times the
observed amounts based upon surveys of our communities. The difference between a projected 587 lost
units and SLOCOG's observed <400 lost units will provide for an ample "margin of error". SLOCOG requests
a reduction of 1000 units from the category of"calculated units needed to replace normal loss of units".
2. Inequitable Distribution of Anticipated Need. SLOCOG realizes that this is not the forum for reallocating
RHNA to all of the surrounding coastal counties, nor are we requesting such of HCD. Yet the fact remains
that our region, with the smallest economy and least amount of infrastructure, is being asked to accommodate
the greatest proportion of regional housing needs of any central coast county. Even if the HCD demographic
model is strictly applied and our housing need is projected to be higher than that of neighboring counties, the
inherent flaw in the HCD projections lies in its ignorance of other factors which directly relate to our region's
ability to facilitate explosive housing growth and the accompanying services such growth predicates.
Counties can serve as manageable regional planning areas, but ignoring the cross-county relationships,
particularly as. they relate to housing choices and residential locations, is poor planning at best and
detrimental to local communities at worst.
The relatively higher housing prices in surrounding counties have undoubtedly contributed significantly to the
domestic out-migration witnessed along the coast between Santa Cruz and Ventura. Up until a few years
ago, San Luis Obispo was a refuge for homebuyers able to find relatively affordable housing that included a
"Central Coast" lifestyle. Such an influx to our area has caused housing prices to rise dramatically and
actually begin to approach prices in our neighboring counties. Because of this set of circumstances, HCD's
projection model, as it is currently used, demands that we continue this trend of absorbing what have been
equity rich migrants into our area. Throughout the 1990's the surrounding counties were (and are still) unable
Or unwilling to provide for an adequate stock of housing options. San Luis Obispo County is clearly being
asked to not only accommodate our own housing needs, but those of surrounding coastal counties, as is
evident by our large proportion of immigration relative to surround areas. The current HCD process and
methodology supports and perpetuates this unhealthy dynamic.
SLOCOG is proposing that this be remedied, studied further, and corrected prior to the next HCD housing
needs allocation process. Until then, the only immediate solution is for HCD to lower the proiection for San
Luis Obispo County by at least 2000 housing units on the basis of the inequalities evident in the proposed
allocation of units to these counties.
3. Components of Change. While strongly interrelated with the issue of distribution of anticipated need, the
details of the components of change can be both indicative of household formation rates and misrepresenting
of future trends. One of the driving forces of San Luis Obispo's observed growth rates marked by high levels
of immigration and moderate levels of natural increase over the last decade, was the fact that housing sites
were relatively affordable, jobs were available and this was, and is, an extremely desirable destination for job
seekers and retirees.
With the notable discrepancy between our housing prices and those of surrounding areas disappearing, the
high rate of immigration witnessed in the 1990's is likely to subside. HCD is basing SLOCOG's regional
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ATTACHMENT qq
housing needs allocation partially upon this immigration trend of recent years yet seems to be ignoring'fhe
driving forces for that migration. .If HCD was to acknowledge why immigration has been a major contributing
factor (i.e. due to our low "beginning point" of affordability, relative ease of project approval, and greater site
availability), the.agency could also recognize that'providing for explosive housing, growth is a self-fulfilling
prophecy for continued rates of high migration and high household formation — and would likely result in a
political backlash to limit growth as evidenced by the number of local initiatives around the state in recent
years. This type of growth would destroy our.sense of community and transform the region into a sprawling
suburbia of homes, lost farmland and wasted resources at a time when public and private agencies are
beginning to shift toward more sustainable development and smart growth practices.
Based upon the demography of the "components of change" used by HCD in their projection model and the
fact that this model has within it inherent flaws which force San Luis Obispo to absorb more than our share of
housing, SLOCOG is reguesting that the number be reduced by 2000 housing units for the planning Period
ending on July 1, 2008.
Our challenge as the Council of Governments, Metropolitan Planning Organization, and Regional
Transportation Planning.Agency for the region lies in effective coordination with our member jurisdictions in
the provision of the right types of housing and other forms of development located in favorable areas linked to
integrated transportation networks. Any new wave of development needs to be designed efficiently and
carefully so as not to overburden our limited resources. Furthermore, mechanisms for securing a range of
funding sources to mitigate the costs of providing affordable housing to our region must be increased and
improved.
Presently, the HCD process for allocating regional housing needs backed by penalties, threats of lawsuits,
and ineligibility for securing the necessary grants to meet the requirements for low-income housing — rather
than being supported by incentive based programs is ineffective. HCD's effort in seeking a regional housing
needs allocation for San Luis Obispo County that is extreme, unfair, and without the proper support
mechanisms will not help the state's housing shortfalls in general, nor will it help the SLOCOG region in
particular. If HCD was to have it's way and thousands of housing units were to be rapidly placed throughout
the county, there is no doubt that our region will be worse off by 2008, not better, lending itself as another Los
Angeles lesson for others to learn about how not to develop.
SLOCOG strongly believes the predicted household growth —and the resultant proposed number of"needed"
housing units estimated by HCD, far exceed the anticipated demand and the capability of local jurisdictions to
serve such growth. It is our intention to continue Working closely with our member jurisdictions and our State
legislators in this process; however, it becomes increasingly difficult if the anticipated housing demand for the
region is based upon inflated estimates and flawed methodologies which ignore the reality of available
resources, the nuances of demographic change,and the historic, present and anticipated housing market.
At the March 6, 2002 meeting, the San Luis Obispo Council of Government's Board opposed adopting a
housing growth plan that is destined to fail due to the extreme nature of the increase in proposed housing
units, the inequitable allocation of units compared to other counties, and that is contrary to foreseen patterns
in migration and housing markets in the coming decade.
Thank you for your attention to this matter. Should you have any questions or concerns, please feel free to
contact Peter Brown at(805)788-2104.
Sincerely
Dave Elliott, President
San Luis Obispo Council of Governments
C. SLOCOG Board
State Senator Jack O'Connell
Assemblyman Abel Maldonado
Linda Wheaton- HCD
Cathy Creswell-HCD
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